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STEM, INC. Regulatory Filings 2021

Jun 10, 2021

34038_rns_2021-06-10_1700fe9e-9766-4962-8450-dd75141461db.zip

Regulatory Filings

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CORRESP 1 filename1.htm

June 10, 2021

VIA EDGAR

United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549

Re: Stem, Inc. Registration Statement on Form S-1 Filed May 26, 2021 File No. 333-256501

Ladies and Gentlemen:

Stem, Inc., a Delaware corporation (the “Company”), respectfully requests pursuant to Rule 461 under the Securities Act of 1933, as amended, that the effective date of the Company’s Registration Statement on Form S-1 (File No. 333-256501) be accelerated and that it be declared effective on June 14, 2021 at 4:00 p.m. Eastern time, or as soon as practicable thereafter.

Please direct any questions regarding this filing to John Gaffney of Gibson, Dunn & Crutcher LLP at (212) 351-2626.

Very truly yours,
STEM, INC.
By: /s/ Saul Laureles
Name: Saul Laureles
Title: Chief Legal Officer and Secretary

cc: Evan D’Amico

Gibson, Dunn & Crutcher LLP

cc: John Carrington Chief Executive Officer William Bush Chief Financial Officer Stem, Inc.

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